Tax regulations in USA affecting
Tax regulations in USA affecting NRIs – Resident Indians
By SANKET SHAH
CO-FOUNDER AND MANAGING DIRECTOR
USA the dream destination
USA the dream destination
USA has always been and will be a
dream destination
Getting a job
Sending kids for education
Getting citizenship of kids by birth
Investments e.g. Company formation,
services Purchase of assets
Providing services,
assets, etc
etc.
EB5 isa allo s dream to be a realit
EB5 visa allows dream to be a reality
A direct route to a Green Card
Investment as low as $500,000
Permanent residency (Green Card) for
Husband, Wife and unmarried kids (below the
age of 21)
Freedom to live, work and retire anywhere in
the United States
Children may attend college or universities at
in-state resident costs.
Becoming a US Citizen 5 years after receiving
unconditional green card
“We are still Indian at heart”
“We are still Indian at heart”
Strong family roots in India (Parents, brothers/sisters, etc.)
Substantial wealth in India
Inheritance
O
Own
Savings
S i
Invest in India to yield high relative return
Property
or rental))
p y ((self occupied
p
Deposits (FCNR, FD’s)
Securities
Indians are moving back
Indians are moving back
US economy no more robust
Indians are moving back
Indians are moving back
India’s economy is gaining momentum
Tax Culture in USA
Tax Culture in USA
Self reporting
Within USA – Linked thru SSN, EIN or TIN
Outside USA – essentially relies on taxpayer’s honesty
Sever penalty on non disclosure
Civil Prosecution (interest and penalty)
Criminal Prosecution (prison)
Tax Culture in USA
Tax Culture in USA
Tax is imposed on INCOME by:
Federal
Majority of States (Only 2 States out of 50 States have NO tax –
Nevada and Wyoming)
Some Local
Credit of Taxes Paid:
F d lL
dit ffor St
t and
dL
At Federal
Levell – credit
State
Locall
At State Level – credit for Local
Individual Tax Culture in USA
Individual Tax Culture in USA
If you are a US Citizen, Green Card Holder or a Resident Alien*,
your worldwide income is subject to US Income Tax,
regardless
g
of where you
y
reside.
Individual Tax Culture in USA
Individual Tax Culture in USA
Example 1:
Mr. A who is a US Citizen (or a Green Card Holder) has been residing in
INDIA for the last 8 years and having his source of Income from
SINGAPORE. He will be liable to pay tax in:
In INDIA
Based on Residency
In SINGAPORE
Based on Source
In USA
Based on Citizenship
US Resident and Nonresident Status
US Resident and Nonresident Status
You are considered a nonresident alien for any period that
you are neither:
a United States citizen nor
a United States resident alien
You are considered a resident alien if you met one of the
following two:
G
C dT
Green
Card
Testt
Substantial Presence Test
Substantial Presence Test
Substantial Presence Test You must have been physically present in the United States on
at least:
31 days during the current year, and
183 days
y during
g the 3 yyear p
period that includes the current yyear and 2 yyears
immediately before. To satisfy the 183 days requirement:
•
Count all the days you are present in the current year, and
•
One-third of the days you were present in the first year before the current
year, and
•
One-sixth of the days you were present in the second year before the
current year
Substantial Presence Test
Substantial Presence Test
Example 2:
You were physically present in the United States on 120 days in each of the
years 2011, 2012, and 2013.
presence test for 2013:
To determine if yyou meet the substantial p
count the full 120 days of presence in 2013,
40 days in 2012 (1/3 of 120), and
20 days in 2011 (1/6 of 120).
Since the total for the 3-year period is 180 days, you are not considered a
presence test for 2013.
resident under the substantial p
Substantial Presence Test
Substantial Presence Test Even though you meet the substantial presence test, you can be
treated as a nonresident alien if:
You are present in the United States for fewer than 183 days during the
current calendar year,
Y maintain
You
i t i a ttax h
home iin a fforeign
i country
t d
during
i th
the year, and
d
You have a closer connection to that country than to the United States.
This does not apply if you have applied for status as a lawful permanent
id t off th
it d St
t
h
li ti pending
di ffor
resident
the U
United
States,
or you have
an application
adjustment of status.
Hence, a person who is on an H1 or L1 and whose company has initiated the
Green Card process cannot be treated as a Non-Resident
Non Resident Alien.
Foreign Students
Foreign Students An individual student who is temporarily present in the United States under an “F,” “J,”
“M,”
, or “Q”
Q visa and who substantiallyy complies
p
with there visa requirements
q
will be
treated as an “exempt individual” for 5 calendar years (2 calendar years for J-1,Q-1 or
Q-2 scholars).
You should have no intention to reside p
permanently
y in the United States.
Thus, a foreign student who enters the United States on December 31, 2012 counts
2012 as the first of his five years as an "exempt individual”.
In addition, students in F-1, J-1, M-1, Q-1 or Q-2 status do not pay US Social Security
and Medicare (FICA) during there exempt period.
Summary
Status
Tax on
Residence
US Citizen and Green
Card Holder
Worldwide income
Regardless of where
you reside
H1 or L1 visa holder
Worldwide income
(subject to some
exception)
Residing
g in USA
F1 visa holder
Worldwide income if
lived more than 5 years
in USA.
Residing
g in USA
Different Individual Tax Returns
Different Individual Tax Returns
Form 1040 – U.S. Individual Income Tax Return. Most widely used.
Form 1040A – A shorter version of Form 1040 and limited to taxpayers with
taxable income below $100,000.
o
1040EZ
0 0
–S
Simplest
p est version
e s o with
t only
o y six
s section
sect o to use a
and
d limited
ted to
Form
taxpayers with taxable income below $100,000.
Form 1040NR – Nonresident Aliens Tax Return.
F
Form
1040NR-EZ
1040NR EZ – Simplest
Si l t version
i off ttax return
t
ffor th
the N
Nonresident
id t Ali
Aliens.
Form 1040X – Amended tax return.
Individual Tax Rates 2014
Individual Tax Rates ‐
Marginal Tax Rate
Single
Married Filing Jointly or Qualified Widow(er)
Married Filing Separately
Head of Household
10%
$0 – $9,075
$0 – $18,150
$0 – $9,075
$0 – $12,950
15%
$9,076 – $36,900
$18,151 – $73,800
$9,076 – $36,900
$12,951 – $49,400
25%
$36,901 – $89,350
$73,801 – $148,850
$36,901 – $74,425
$49,401 – $127,550
28%
$89,351 – $186,350
$148,851 – $226,850
$74,426 – $113,425
$127,551 – $206,600
33%
$186,351 – $405,100
$226,851 – $405,100
$113,426 – $202,550
$206,601 – $405,100
35%
$405,101 – $406,750
$405,101 – $457,600
$202,551 – $228,800
$405,101 – $432,200
39.6%
$406,751 +
$457,601 +
$228,801 +
$432,201 +
“Pass through entities”
“Pass‐through entities”
The phrase "pass-through entity" means that profits are not taxed to
corporation Instead
corporation.
Instead, 100% of profits (or losses) are distributed (or passedthrough) to the shareholders. Each shareholder reports his or her share of
profits or losses on his or her individual tax return (Form 1040).
Pass-through entities taxed at the shareholder level are:
Sole proprietors,
S-Corporations,
Partnerships, and
LLC/LLP/PLLC/PLLP taxed as partnerships
Corporations
Two types of Corporations: C Corporations and S Corporations.
S corporations are not taxed at the corporate level, and their shareholders
are taxed on the corporation's income as it is recognized.
Corporations which are not S Corporations are known as C Corporations.
C Corporations earnings are taxed twice. First, a Corporate income tax is
imposed on its net earnings and then, after the earnings are distributed to
shareholders as dividends, each shareholder must pay taxes separately on
their share of dividends.
NRI Investments
NRI Investments
Investment
Income
Tax Implication in
India
USA
NRE / FCNR deposit
Interest
Non Taxable
Taxable
Fixed deposit
Interest
Taxable
Taxable
NRO deposit
Interest
Taxable
Taxable
PPF deposit
Interest
Non Taxable
Taxable
Property
Capital Gains
Taxable
Taxable
Rental Income
Taxable
Taxable
Capital Gains
Non Taxable (Long term)
Taxable
Dividend
Non Taxable
Taxable
Securities (Listed)
Estate Gift and GST Tax
Estate, Gift and GST Tax
The estate, gift and generation-skipping transfer (GST) taxes were designed
t form
to
f
a unified
ifi d ttransfer
f tax
t system
t
on the
th transfer
t
f off property
t att death
d th
(estate tax), during life (gift tax), and on transfers that skip a generation
(GST tax).
Although gift taxes and estate taxes are paid separately, they are a unified
tax in the sense that a single graduated rate schedule applies to the
cumulative total of taxable transfers made through gifts and estates.
Gift Tax
Gift Tax
Gift tax applies to the transfer of property, including money or the use of or
income from p
property.
p y Most g
gifts above the annual exemption
p
are still not
subject to tax because each taxpayer is allowed a lifetime credit against
taxable gifts and estate.
Type
yp
Exemption
p
Excess Tax
Rate
Annual Exclusion
$14,000 during the calendar year
to each donee.
40%*
Educational
Ed
ti
l and
dM
Medical
di l P
Payments
t
directly to the organization
U li it d
Unlimited
Gifts to Spouse
Unlimited (to US Citizen spouse)
$145,000 (to Noncitizen spouse)
40%
Estate Tax
Estate Tax
As Per IRS - “The Estate Tax is a tax on your right to transfer property at
your deat
you
death”.
The amount of tax is determined by applying the relevant tax rates to the
taxable estate, that is the gross estate reduced by any deductions.
The value
Th
l off property
t th
thatt is
i included
i l d d iin th
the gross estate
t t is
i itits fair
f i market
k t
value on the date of the death of the decedents death.
Y
Year
2015
E
Exemption
ti
E
Excess
T
Tax Rate
R t
$5.43 million (inflation adjusted)
$10.86 million for a couple
40%
Estate Tax
Estate Tax
Example 3:
Mr. A who is a US Citizen moved to India in 2002 and has been residing in
INDIA since then. In 1995, he purchased a house in USA for $1.5 million. On
arrival in India, he purchase a flat for $2 million.
Mrs. A had passed away in 2000 and they are survived by there only child
Mr. X, who is a US Citizen and residing in USA.
p y was $2.00
$
million,,
On 1/1/2015,, the Fair Market Value of the US Property
Indian Property was $4.00 million and his other assets were worth $2.43
million.
Estate Tax
Estate Tax
Mr. A dies on
01/01/2015
US Property
$2.00 million
Indian Property
$4.00 million
Other Assets
$2 43 million
$2.43
Total Wealth
$8.43 million
Less: Lifetime Exclusion
$5.43 million
N tW
Net
Wealth
lth
$3 00 million
$3.00
illi
Estate Tax @
Estate Tax
40%
$1.20 million
Estate Tax
Estate Tax
Example 4:
Mr. A, age 70, is an Indian Citizen by birth. His total wealth in India is $3.43
million. Mrs. A had passed away in 2000. They are survived by there only
child Mr. X, age 45 who is a US Citizen and residing in USA.
Mr. X is a divorce and has a daughter Ms. H, age 20. Mr. X currently owns a
US Property worth $3.50 million and other assets worth $2.50 million.
p his will Mr. X becomes the sole
On June 30,, 2012 Mr. A dies and as per
owner of his wealth.
Estate Tax
Estate Tax
Mr. X dies on
01/01/2015
US Property
$3.50 million
Wealth (inherited)
$3.43 million
Other Assets
$2 50 million
$2.50
Total Wealth
$9.43 million
Less: Lifetime Exclusion
$5.43 million
N tW
Net
Wealth
lth
$4 00 million
$4.00
illi
Estate Tax @
Estate Tax
40%
$1.60 million
Generation skipping transfer Tax
Generation‐skipping transfer Tax
The U.S. Generation-skipping transfer tax imposes a tax on:
Outright gifts and transfers in trust to or for the benefit of unrelated persons who
are more than 37.5 years younger than the donor, or
To related persons more than one generation younger than the donor, such as
grandchildren.
The generation-skipping tax will be imposed only if the transfer avoids
incurring a gift or estate tax at each generation level.
Controlled Foreign Corporation (“CFC”)
Controlled Foreign Corporation (“CFC”)
CFC provisions applicable in case of a US Shareholder who
holds atleast 10% of a Non-US corporation and the NonUS corporation is more than 50% owned (by vote or value)
byy one or more US persons.
p
Certain income of CFC is to be included on pro rata basis in
the gross income calculation of the US shareholders.
Passive Foreign Investment Company (“PFIC”)
Passive Foreign Investment Company (
PFIC )
A PFIC is any Non-US company that:
Derives more than 75% of its income from passive sources or
50% of its assets generate passive income.
Passive income generally includes income that is dividends,
interest, rents, royalties etc.
PFIC include foreign-based mutual funds, partnerships and other
pooled investment vehicles that have at least one U.S. shareholder.
Income of PFIC is to be included on pro rata basis in the gross
income calculation of the US shareholders.
NRA Withholding requirement
NRA Withholding requirement
The NRA withholding tax is generally withheld from the payment made to the
foreign person.
person
Most types of U.S. source income paid to a foreign person are subject to a
U.S. withholding tax of 30 percent.
A reduced rate, including exemption from tax, may apply by virtue of an
Internal Revenue Code section or a provision of a tax treaty between the
foreign person's country of residence and the United States.
Disclosure Requirements
Disclosure Requirements
Report of Foreign Bank and Financial Accounts (the “FBAR”):
Type
Financial interest in
financial institution
outside USA
Threshold
Aggregate value of
all foreign account
exceeded $10,000 at
any time during the
year
Non-willful
penalty
$10 000
$10,000
Willful penalty
greater of $100,000
$100 000
or 50% of the total
balance of the
foreign account.
Treasury Department Form 114 is due June 30th of each year to report
foreign bank accounts owned in the previous year.
IRS Disclosure Requirements
IRS Disclosure Requirements
Type
Threshold
A US Person
who has
received gift
or bequests.
a. More than $100,000 from a
nonresident alien individual or a
foreign estate that was treated as gifts
or beques
o
bequests
s by the
e US Person;
e so ; o
or
b. More than $15,358 from foreign
corporations or foreign partnerships
that was treated as gifts by the US
Person.
Person
Penalty
Greater of $10,000 or
5% of the gift per month, up to
maximum of 25% of the gift.
The due date for disclosing the above details is on the date that your income
tax return is due ((April
p 15th), including
g extensions (October
(
15th)).
IRS Disclosure Requirements
IRS Disclosure Requirements
Type
A US Person who
a. is treated as the owner of
any part of the assets of a
foreign trust
trust, or
b. transfers property to a
foreign trust, or
c. receives a distribution from
a foreign
f i trust.
t t
Threshold
NONE
Penalty
Greater of $10,000 or:
a.
35% of the gross value
transferred to a foreign
trust
b.
35% of the gross value of
the distributions received
from a foreign trust.
The due date for disclosing the above details is on the date that your income
tax return is due ((April
p 15th), including
g extensions (October
(
15th)).
IRS Disclosure Requirements
IRS Disclosure Requirements
Type
Threshold
Penalty
A US Person
who has an
investment
in a foreign
o eg
corporation
A US Person who has acquired:
•
10% or more of the total value of
the foreign corporation, or
•
10% or more of the total combined
voting power of all classes of
stock with voting rights
Penalty for failing to file is
$10,000, with an additional
$10,000 added for each month
after
a
e 90 days o
of the
e de
delinquency,
que cy,
upto a maximum of $50,000.
The due date for disclosing the above details is on the date that your income
tax return is due (April 15th), including extensions (October 15th).
IRS Disclosure Requirements
IRS Disclosure Requirements
Type
A US Person
who has an
interest in a
foreign
o eg
partnership
Threshold
A US Person who owned:
• 10% or greater interest in the
partnership
• Contributed value of property
exceeding $100,000.
Penalty
Penalty for failing to file is
$10,000, upto a maximum of
$50,000 or 10% of the value of
any
a
y transferred
a s e ed p
property
ope y that
a is
s
not reported subject to
$100,000
“interest” means: Capital, profits or losses.
The due date for disclosing the above details is on the date that your income
tax return is due (April 15th), including extensions (October 15th).
Criminal Penalties
Criminal Penalties
Tax evasion
5 years prison and fine upto $250,000
False return
3 years prison and fine upto $250,000
Failing to file tax return
1 year prison and fine upto $100,000
Willful Non filing of FBAR form 10 year prison and penalties upto
$500,000
Exit tax
Exit tax
If you decide to relinquish your US Citizenship or Green Card (held for at least 8 out of
the last 15 tax years), you will be required to pay exit tax if you meet any one of the
three tests:
Income tax test:
The expatriate's average annual U.S. income tax liability over the 5 years prior
to expatriation was over $157,000 (for the year 2014).
Net worth test:
The expatriate's net worth is at least $2 million.
Compliance test:
The expatriate does not certify that he met all U.S. tax obligations for the five
years before expatriation.
The UBS issue
The UBS issue
In 2008 IRS served summons to Swiss bank UBS.
a
a.
In return UBS supplied details of 17
17,000
000 U
U.S.
S taxpayers with 52
52,000
000 UBS
accounts to IRS.
b.
Admitted that it fostered tax evasion from 2000 to 2007
c
c.
Paid $780 million to avoid prosecution
d.
Raoul Weil Chairman and CEO Global Wealth Management & Business
Banking at UBS was indicted and declared a fugitive after failing to surrender
to U.S. authorities on charges of conspiring to help wealthy Americans hide
assets to avoid paying taxes
The HSBC issue
The HSBC issue
In 2011 Department of Justice (“DOJ”) filed a petition seeking leave to serve
what is known as a "John Doe" summons on HSBC.
a.
IRS was seeking information for 9000 US taxpayers of Indian descent from
HSBC India having minimum balance of $100,000.
b.
g that “they
y had received an IRS
HSBC sends letter to its customers stating
summons seeking the names of Americans who hold accounts at the bank”.
c.
HSBC terminated "private banking services to US persons and certain trusts
and non-operating companies connected to US persons”
d.
HSBC no longer offers wealth management services to US resident private
clients from locations outside the US.
e.
HSBC sells 195 retail banking branches in US to First Niagara Financial
Group Inc.
Inc for $1 billion in cash.
cash
US Amnesty Scheme
US Amnesty Scheme
Following the UBS and HSBC scandal, IRS came up immediately with
Amnesty scheme:
In 2009 - Offshore Voluntary Disclosure Program (OVDP)
Approximately 18,000 taxpayers came forward
Collected $
$3.40 billion in tax,, interest,, and penalties
p
reflecting
g closures
of about 95 percent of the cases.
In 2011 - Offshore Voluntary Disclosure Initiative (OVDI)
Approximately 12,000 taxpayers came forward
$1.00 billion in taxes and interest as down payments. A figure that will
increase because it doesn’t yet include penalties.
On January 9th 2012 – IRS reopens OVDP
From 8938
From 8938
Taxable years beginning on or after 1st January, 2011 U.S. taxpayers
holding financial assets outside the United States must report those
assets to the IRS on a new form (8938) attached to their tax return.
Specified Foreign Financial assets include:
Any financial
f
account maintained by a foreign
f
financial
f
institution (“FFI”)
(“ ”)
Assets held for investment other than maintained by FFI, like:
Stock or securities issued by other than a US person
Any interest in a foreign entity
Any financial instrument or contract that has an issuer other than a
US Person
US introduces FATCA
US introduces FATCA
Foreign Account Tax Compliance Act (“FATCA”)
•
Foreign financial institutions (FII’s) will need to enter into an
agreement with the IRS that requires them to report directly to the
IRS certain information about financial accounts held by U.S.
taxpayers, or by foreign entities in which U.S. taxpayers hold a
substantial ownership interest.
•
30 percent withholding tax on financial institutions that that do not
comply with reporting.
Worldwide sharing of information
Worldwide –
sharing of information
As of December 15th, 2014: 52 jurisdictions have signed
intergovernmental agreement with the US Treasury Department under
FATCA.
As of December 15th, 2014: 60 jurisdictions have reached
agreements in substance with the US Treasury Department under
FATCA. India is one of them who has agreed in substance.
On December 22nd, 2014: The Government of India (as per the article
in Economic Times) has shown its desire to sign the intergovernmental
agreement with US before the end of the year 2014.
Case Study A
Case Study A
Mr. A who is a US Person (Citizen /GC holder) and a resident of US, decides
to remit money to India for investment in FD
FD’s,
s, Securities and Property.
Transaction
Type of
Compliance
Threshold
Non-Compliance Penalty
Funding the
Bank in India
FBAR
Disclosure
In excess of $10,000
$10 000
Non Willful - $10,000
$10 000
Willful - $100,000 or 50% of the total
balance of the foreign account.
Criminal – 10 years imprison and
penalties upto $500,000
Bank and FD’s
Interest
Tax Return
Interest income from Bank
NRO/NRE or FCNR deposit
are taxable in US even though
tax free in India.
Tax Evasion - 5 years prison and fine
upto $250,000
False Return - 3 years prison and fine
upto $250,000
Case Study A
Case Study A
Transaction
Type of
Compliance
Threshold
Non-Compliance Penalty
Securities
Tax Return
Dividend and Capital Gain are
taxable in US even though tax
free in India.
Tax Evasion - 5 years prison and fine
upto $250,000
False Return - 3 years prison and fine
upto $250,000
Securities
IRS
Disclosure
More than 10% holding in any
Corporation
$10,000, with an additional $10,000
added for each month after 90 days
of the delinquency, upto a maximum
of $50,000
Property
Tax Return
Rental Income and Capital
Gains needs to be disclosed in
US even though tax paid in
India.
Tax Evasion - 5 years prison and fine
upto $250,000
False Return - 3 years prison and fine
upto $250,000
Case Study B
Case Study B
Mr. B is a US Person (Citizen /GC holder) and a resident of India. During the
year 2015, he:
1. Receives Salary of Rs. 36 lacs annually
2. Receives a gift of $200,000 from his mother.
3 Becomes a managing partner in a partnership with 25% share in profits
3.
and loss.
4. Receives share of profit from the partnership of Rs. 10 lacs
Case Study B
Case Study B
Transaction
Type of
Compliance
Threshold
Non-Compliance Penalty
Salary
Tax Return
None. Has to be disclosed.
Tax Evasion - 5 years prison and fine
upto $250,000
False Return - 3 years prison and fine
upto $250,000
Salary
FBAR
Disclosure
Salary deposited in the bank
account in excess of $10,000.
Non Willful - $10,000
Willful - $100,000 or 50% of the total
balance of the foreign account.
Criminal – 10 years imprison and
penalties
lti upto
t $500
$500,000
000
Gift received
IRS
Disclosure
More than $100,000
Greater of $10,000 or 5% of the gift
per month, up to maximum of 25% of
the gift.
Case Study B
Case Study B
Transaction
Type of
Compliance
Threshold
Non-Compliance Penalty
Partnership
interest
IRS
Disclosure
More than 10%
$10,000, upto a maximum of $50,000
or 10% of the value of any transferred
property that is not reported subject
to $100,000
Partnership
FBAR
Disclosure
Signing authority in the bank
account.
Non Willful - $10,000
Willful - $100,000 or 50% of the total
balance of the foreign account.
Criminal – 10 years imprison and
penalties upto $500
$500,000
000
Share of Profit
from
Partnership
Tax Return
None. Has to be disclosed, Tax
free in India, still taxable in US.
Credit shall be claimed for
taxes paid by the partnership.
partnership
Tax Evasion - 5 years prison and fine
upto $250,000
False Return - 3 years prison and fine
upto $250
$250,000
000
Conclusion
NRIs residing in US need to:
Structure their Indian investments for:
Avoidance of Double Taxation
Compliance with tax provisions of both US as well as India
Report their Indian income and investments to IRS in US
Plan estate and inheritance from Indian Parents
Conclusion
US Persons residing in India need to:
Report their Indian income to IRS in US
Comply with the Disclosure provisions of US
Pay taxes on the Indian income to US (subject to relief under
Double Taxation treaty)
Plan estate and inheritance from Indian Parents
Plan estate for their next generation
Question & Answer session
IRS Circular 230 Legend
IRS Circular 230 Legend
Pursuant to requirements relating to practice before the
United States Internal Revenue Service, any tax advice in
this communication (including any attachments) is not
intended to be used, and cannot be used, for the purpose of
(i) avoiding
idi penalties
lti imposed
i
d under
d the
th United
U it d States
St t
Internal Revenue Code, or (ii) promoting, marketing, or
recommending to another person any tax-related matter.
Contact details Sanket Shah
Contact details –
Sanket Shah
Address:
B 41-45, Paragon Centre,
Pandurang Budhkar Marg,
Marg Worli,
Worli
Mumbai – 400 013
Phone Number:
+91 22 4073 3070 / 71
Cell Number:
+91 9820666100
Email ID:
sanket@nsglobal.com
Website:
www.nsglobal.com
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